BACKGROUND:
JSA Psychotherapy Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and service users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Our company name is JSA Psychotherapy Limited.
We are a limited company and we are registered in England under company number 06033750.
Registered address: 47 Bedwin Street, Salisbury SP1 3UT.
Data Protection Officer: Tom Baker-Price.
Email address: dpo@five-rivers.org
Telephone number: 01722 435750.
This Privacy Information explains how We use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that We use is set out in Part 5, below.
Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data We hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to Us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to Us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact Us first, using the details in Part 11.
We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.
| Data Collected | How We Collect the Data |
| Identity Information including Name, title, date of birth, gender and personal signature
|
Data collected via online referral form, medical form completion and professional agreements.
|
| Contact information including Email address, telephone numbers, home addresses
|
Data collected via online referral form, medical form completion and professional agreements.
|
| Payment information including sort code, account number and name of account.
|
Data collected via online payment method for therapy sessions.
|
| Data from third parties including contact information, copies of previous reports, detailed background history. This may include sensitive data relating to health.
|
Data collected by social worker or solicitor sharing data to our service in readiness for a programme of therapy starting.
|
| Sensitive data relating to health such as medications, diagnoses and symptoms.
|
Our direct interactions with you during the provision of therapy services to you.
|
Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We will use your personal data, and our lawful bases for doing so.
As we will collect and process sensitive personal data as outlined above and below our lawful basis for doing so will be your express consent. Accordingly prior to commencing any therapy we will issue you with a hard copy of this privacy notice and will ask you to sign the notice to expressly and explicitly consent to the processing of your sensitive personal data.
| What We Do | What Data We Use | our Lawful Basis |
| Administering our business and communicating with you. | Identity Information including Name, title, date of birth, gender and personal signature Identity Information including Name, title, date of birth, gender and personal signature.
Contact information including Email address, telephone numbers, home addresses
|
Legitimate interests – to maintain records of our service users and communicate with them.
The performance of a contract. |
| Supplying our services to you. | Identity Information including Name, title, date of birth, gender and personal signature Identity Information including Name, title, date of birth, gender and personal signature.
Contact information including Email address, telephone numbers, home addresses.
Data from third parties including contact information, copies of previous reports, detailed background history. This may include sensitive data relating to health.
Sensitive data relating to health such as medications, diagnoses and symptoms. |
The performance of a contract. |
| Managing payments for our services. | Payment information including sort code, account number and name of account. | Legitimate interests – to receive payment for the provision of services.
The performance of a contract. |
| Providing therapy services to you. | Sensitive data relating to health such as medications, diagnoses and symptoms.. | Explicit consent – see information above. |
We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 11.
If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.
In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Details of how long we keep your personal data and how it is stored are set out in our data retention policy which is available on request.
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for the purpose of administering our business as this is in our legitimate interests and where it is necessary to comply with a legal obligation relating to tax and accountancy purposes. This includes subsidiaries our holding company and its subsidiaries.
If We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request no more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.
To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Tom Baker-Price):
Email address: dpo@five-rivers.org
Telephone number: 01722 435750.
Postal address: 47 Bedwin Street, Salisbury SP1 3UT.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection. Any changes will be made available on our website. This Privacy Notice was last updated on 25th September 2024.
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